Life Perspectives, Spring 2020
Vol 3 | No. 2
New PBR Practice Note Released
The Life Valuation Committee’s Principle-Based Reserve Review (PBR) Procedures Work Group released a public policy practice note in mid-April, Common Practices of Examining Actuaries Involved in Statutory Financial Solvency Examinations of Life and Health Insurers, Including Considerations for PBR.
The document is intended primarily to assist examining actuaries in coordinating with examiners in charge and in effectively conducting risk-focused examinations. The approach is based on an examining actuary being an integral member of the examination team.
The practice note “will help examining actuaries bring more value to the risk-focused examination approach and be more integrated in the risk identification, risk assessment, and risk mitigation aspects of the financial examination process,” said work group Chairperson Randall Stevenson. “There is so much more to a risk-focused examination than validating the correctness of reserves. It is more about the processes used to ensure the reserves are and will continue to be correct. As an analogy, a broken clock is right twice a day, instead of verifying it has the correct time when checked, the risk-focused approach is intended to make sure it is running properly.
“The practice note is not only for examining actuaries, but for actuaries whose work is subject to statutory examinations. It is intended to provide them with an idea of how to better prepare for an examination, respond to requests for information, and understand what examiners are likely to ask—and why,” Stevenson said.
“The work group was comprised of nearly equal representations of actuaries employed as regulators, consulting actuaries who perform examinations for regulators, and actuaries whose work is subject to examination,” he said. “This blended representation was intended to help produce a practice note understandable by and beneficial to all of the actuaries who are stakeholders in financial examinations.”
PBR Practice Note Updated
The Life Principle-Based Approach Practice Note Work Group updated the practice note, Life Principle-Based Reserves (PBR) Under VM-20, previously released in 2017, to reflect emerging practices and changes to the Valuation Manual since the version effective for Dec. 31, 2019, valuations.
Task Force Comments on ASOP No. 11 Exposure Draft; ASB Extends Comment Deadline
The Actuarial Standards Board (ASB) has extended the comment deadline for the exposure draft of Actuarial Standard of Practice (ASOP) No. 11, Reinsurance Involving Life Insurance, Annuities, or Health Benefit Plans in Financial Reports.
The Life Practice Council formed a task force to review the exposure draft that in mid-April sent a comment letter to the ASB on the exposure draft. The letter addresses issues including whether the scope description relating to the inclusion of self-insurance was clear; whether the guidance is sufficient given current laws, regulations, and accounting rules; whether there were any areas where the guidance is inconsistent with current practice; whether there are areas where the guidance creates issues with reinsurance regulatory requirements; and whether there are areas where the guidance creates conflict or introduces ambiguity with reinsurance-related guidance in other ASOPs.
The ASB’s comment extension is due to the coronavirus pandemic and its worldwide impact on normal business operations, which may have impeded individuals or organizations from submitting comments. The ASB received requests to extend the deadlines from several committees and task forces of the Life Practice Council, as well as the Pension Practice Council for a separate ASOP comment deadline extension. The new comment deadline for ASOP No. 11 is June 30. The ASB exposure draft can be viewed here.
Capitol Forum Cross-Practice Webinar Will Cover COVID-19 Issues
The Academy will host a cross-practice webinar on April 28, covering the COVID-19 pandemic. To be moderated by Academy President D. Joeff Williams, the Capitol Forum webinar will feature the Academy’s practice-area senior fellows, including Senior Life Fellow Nancy Bennett. The webinar will be held from noon to 1:30 p.m. EDT, and continuing education credit will be available. Register today.
NAIC Releases RBC Calculations Guidance
The National Association of Insurance Commissioners (NAIC) has released guidance for 2020 Life Risk-Based Capital calculations for debt restructuring and has released proposed modifications for the methodology used in reporting losses.
The NAIC Financial Condition (E) Committee released guidance to U.S. insurers in an effort to encourage them to work with borrowers who are unable to or may become unable to meet their contractual payment obligations because of the effects of COVID-19. The guidance applies to a troubled debt restructuring issued as a result of COVID-19 and is applicable to the term of the loan modification, but solely with respect to a modification, including a forbearance arrangement, an interest rate modification, a repayment plan, and any other similar arrangement that defers or delays the payment of principal or interest, which occurs during the applicable reporting period for a loan that was not more than 30 days past due as of Dec. 31, 2019.
Public Policy Outreach
Principle-Based Reserve (PBR) Analysis Templates Task Force member Rachel Hochberg and Academy member Shari Brockett were among three sets of Academy presenters at the Feb. 25 meeting of the Actuaries Club of Philadelphia. They presented a “PBR Assumptions Resource Manual Introduction,” discussing how the manual published in January 2019 provides a potential framework for updating valuation assumptions and walking through a term lapse margin case study.
Life Groups Comment to NAIC
Life groups commented to the NAIC on several issues in the past several months.
Macroprudential Task Force on Liquidity Stress Testing
The Macroprudential Task Force sent a comment letter to the NAIC Financial Stability (EX) Task Force and Liquidity Assessment (EX) Subgroup on the exposed Liquidity Stress Testing Framework. The task force wrote that a realistic implementation timeline should be followed; the proposed liquidity scenarios should be further developed; and an intended level of stress severity should be described, and scenarios should be developed in a manner consistent with the intended level.
Life Illustrations Comments on IUL Policies
The Life Illustrations Work Group sent a comment letter to NAIC’s Indexed Universal Life (IUL) Illustration (A) Subgroup about Guideline XLIX (AG 49) and illustrations of IUL insurance policies. The letter noted two types of usage (Type A and Type B) and offered four principles for evaluating potential changes to AG 49.
Work Group Submits Comments on Model #787, AG 48
The Life Reinsurance Work Group sent a comment letter to the NAIC Reinsurance (E) Task Force regarding the task force’s exposed memorandum, which requested comments on whether compliance with Actuarial Guideline XLVIII (AG 48) should be considered to be “substantially similar” to Model #787 under the NAIC Financial Standards and Accreditation Program.
Task Force Comments on Longevity Risk
The Longevity Risk Task Force sent a comment letter on the proposed longevity risk charge to the NAIC Life Risk-Based Capital (E) Working Group. While noting there are two different versions of the risk-based capital (RBC) worksheet and instructions included in the exposure, the task force wrote that it “support[s] the first structure that provides for an explicit correlation assumption and do[es] not support the second, which keeps correlation implicit in the formula and restricted to a value of 100%.”
Illustrations Work Group Comments to LATF
The Life Illustrations Work Group sent a comment letter to the NAIC’s Indexed Universal Life (IUL) Illustration (A) Subgroup addressing the subgroup’s questions on illustrations of Indexed Universal Life (IUL) insurance policies under Actuarial Guideline XLIX (AG 49). The work group suggested modification to Section 3.C.vi. to clarify that multipliers will not create additional benchmark index accounts (BIAs), though additional clarification might be needed if the intent is that additional BIAs are only for products with different levels of account charges that offer different levels of cap rates.
It also suggested that the definition of “Supplemental Option Budget” be modified to be “Supplemental Hedge Budget,” to allow for consistency of wording within AG 49 (Section 5, “companies engaging in a hedging program”) and to recognize the use of hedge instruments other than options.
Annual Meeting to Feature Historian Michael Beschloss, Political Analyst Charlie Cook
Registration is open for the Academy’s scheduled 2020 Annual Meeting and Public Policy Forum, which will feature two highly respected speakers who will weigh in on this year’s national election, just days after it occurs.
The Annual Meeting and Public Policy Forum will be held Nov. 5–6 at the Fairmont Hotel in Washington, D.C. Continuing education credit will be available. Discounted early registration rates are now available—register today.
Registration Open for LHQ Seminar
Registration is open for the Academy’s 2020 Life and Health Qualifications Seminar. This annual seminar sells out every year because it delivers the highest-quality and most efficient way to obtain needed basic education or relevant continuing education (CE) credit necessary to qualify to issue actuarial opinions for either the NAIC Life and Accident & Health (A&H) Annual Statement or the NAIC Health Annual Statement. The seminar is scheduled for Nov. 9–12 at the suburban Washington, D.C., Crystal Gateway Marriott in Arlington, Va. (new location for this year). Register now and save—discounted registration rates are now available.
Register With Confidence for Academy Events: New Cancellation Policy
The Academy is monitoring the ongoing coronavirus pandemic situation and adhering to the guidelines surrounding in-person events and large gatherings. While we are moving forward with our fall event schedule—including the marquee Annual Meeting and Public Policy Forum—we also want our members to be able to register with confidence knowing it’s important to you, and the Academy, to try to anticipate a return to normalcy. The Academy now has cancellation policies in place to accommodate any necessary change to your registration resulting from a continuation of the current pandemic situation.
So you can rest easy as you register for our fall events—we look forward to seeing you in person later this year. You can find the cancellation policy for the annual meeting registration page here and the LHQ Seminar here.